SlideShare a Scribd company logo
1 of 112
Download to read offline
Regulatory Affairs Training

                                FAA Relations




Aviation Technology Solutions                   1
Program

        1.          Introductions and Expectations
        2.          JDA Background
        3.          Current Operating Environment
        4.          Goals and Objectives
        5.          FAA Processes and Procedures
        6.          Pro Active Solutions
        7.          Summary and Feedback



Aviation Technology Solutions                        2
Introductions and Expectations

     Briefly state name and responsibilities

     Please share your expectations for course

     Please share example of FAA
      interface/confrontation

     Additional “war stories” during course
      welcome – limit to 2 minutes please


Aviation Technology Solutions                         3
Aviation Technology Solutions   4
Current Operating Environment

     Lawmakers Outraged by FAA Safety Violations
       House Transportation & Infrastructure Hearing
                               April 3, 2008
               Operators are no longer FAA customers
               Whistleblowers are heroes
                               New Office under Chief Counsel (AAE)
     CMO/FSDO Standardization - GAO Report
     “Informal” Field Station Visit Results




Aviation Technology Solutions                                          5
Current and Future
                                   Operating Environment
 Regulatory Compliance Environment
 Evolution of Surveillance/Oversight Process
                  Air Transportation Oversight System (ATOS)
                               Part 121
                  System Approach for Safety Oversight (SASO)
                               Parts 121, 135, 145
                               Deploy in 2103




Aviation Technology Solutions                                    6
Current and Future
                                Operating Environment
     Safety Management System (SMS)
               Parts 121, 139 Final Rule NLT Oct 2012
               Other Certificated Operators 135, 145 TBD
               New Entrant 121 operators
                                   Must include SMS as part of formal application

     SAS will provide oversight function and aligned with
             SMS to ensure AFS “SAS” Safety Assurance System




Aviation Technology Solutions                                                        7
Key FAA HQ Management




        Michael Huerta
        Acting FAA Administrator


                                   Peggy Gilligan
                                   Associate Administrator
                                   for Aviation Safety
                                                             John Allen
                                                             Director Flight Standards Service




Aviation Technology Solutions                                                           8
Aviation Technology Solutions   9
Aviation Technology Solutions   10
Record Fines
                                                      FAA
                                       • Already collected twice as much
                                       in fines then in final two years of
                                       Bush presidency.

                                       • Fines are weighing on carriers
                                       that recently reported first
                                       collective profit in 2 1/2 years.
                                       “The pendulum has swung pretty
                                       hard.’’

                                       •Levied $4.77 million in penalties
                                       since Obama took office, 84%
                                       percent jump from 2007-2008.

                                       • Proposed $77.4 million in fines
                                       9/09 – 9/10 up 66 percent from
                                       9/07-9/08.

Aviation Technology Solutions                                        11
Significant Proposed Fines 2011 Part 121

        Operator                Type         Date        Proposed Fine   Alleged Violation
        Horizon Air                    121    12/09/11     $777,000      Maintenance non compliance
        Evergreen Air                  121    11/11/11     $180,000      Operations non Compliance
        Skywest                        121    10/21/11     $160,000      Maintenance non compliance
        Pinnacle                       121    10/21/11    $1,000,000     Maintenance non compliance
        Colgan Airlines                121    09/15/11    $1,892,000     Operations non Compliance
        Alaska Airlines                121    09/09/11     $590,000      Maintenance non compliance
        Capital Cargo                  121    08/29/11     $298,500      Maintenance non compliance
        American Eagle                 121    08/10/11     $155,000      Operations non Compliance
        American Eagle                 121    07/11/11     $77,500       Maintenance non compliance
        Atlantic Southeast             121    07/11/11     $132,000      Maintenance non compliance
        Federal Express                121    07/08/11     $689,800      Operations non Compliance
        Air Tran                       121    06/23/11     $250,000      Maintenance non compliance
        United Airlines                121    06/17/11     $584,375      Operations non Compliance
        Atlantic Southeast             121    06/16/11     $425,000      Maintenance non compliance
        Lynx Aviation                  121    04/08/11     $350,000      Maintenance non compliance
        Executive Airlines             121    03/30/11     $550,000      Maintenance non compliance
        Skywest                        121    01/18/11     $359,000      Ops and Maint non Compliance
         Total Proposed 121                              $8,470,175



Aviation Technology Solutions                                                                           12
Significant Proposed Fines 2011
                                Part 145 and 135 and Manufacturers
          Streamline Aviation              145        10/21/11        $241,200            Maintenance non compliance
          Aviaton Technical Services       145        09/12/11       $1,100,000           Maintenance non compliance
          Aviation Specialities            145        07/11/11        $77,000             Maintenance non compliance
          Jet Aircraft Miami               145        07/11/11        $66,000             Maintenance non compliance
          Pemco World Aviation Svcs        145        01/21/11        $170,000            Operations non Compliance
          San Antonio Aerospace            145        01/20/11       $1,025,000           Operations non Compliance
           Total Proposed 145                                       $2,679,200
          Parachute Center                 135        08/29/11          $269,000          Maintenance non compliance
          Ameriflight                      135        08/26/11          $262,000          Operations Non Compliance
          Liberty Jet                      135        07/11/11           $75,000          Operations Non Compliance
          Apollo Aviation                  135        07/11/11           $77,300          Maintenance non compliance
          Jet Smart                        135        07/11/11          $133,900          Maintenance non compliance
          26 North Aviation                135        07/11/11           $81,000          Maintenance non compliance
          Bimini Island Air                135        07/11/11   Certificate Revocation   Regulatory Violation
          ERA Helicopters                  135        07/08/11          $194,249          Operations Non Compliance
          Corporate Air                    135        02/17/11          $585,275          Maintenance non compliance
          Heli-Dudes*                      135        01/06/11          $330,000          Regulatory Violation
           Total Proposed 135                                        $2,007,724

          Cessna                       Manufacturer   09/22/11        $2,400,000          Manufacturing Process
          Boeing                       Manufacturer   06/27/11        $1,050,000          Regulatory Violation
           Total Proposed Mfg                                        $3,450,000



Aviation Technology Solutions                                                                                          13
Part 121 Fine Data Jan 2007 – Sept 2011
                                                                                     Fines Levied

                                                         Part 121 Cumulative Fines in $
           $14,000,000.00
           $12,000,000.00
           $10,000,000.00
             $8,000,000.00
             $6,000,000.00
             $4,000,000.00
             $2,000,000.00
                                $-
                                                             Jul. 2007




                                                                                                             Jul. 2008




                                                                                                                                                             Jul. 2009




                                                                                                                                                                                                             Jul. 2010




                                                                                                                                                                                                                                                             Jul. 2011
                                                 Apr. 2007




                                                                                                 Apr. 2008




                                                                                                                                                 Apr. 2009




                                                                                                                                                                                                 Apr. 2010




                                                                                                                                                                                                                                                 Apr. 2011
                                     Jan. 2007




                                                                                     Jan. 2008




                                                                                                                                     Jan. 2009




                                                                                                                                                                                     Jan. 2010




                                                                                                                                                                                                                                     Jan. 2011
                                                                         Oct. 2007




                                                                                                                         Oct. 2008




                                                                                                                                                                         Oct. 2009




                                                                                                                                                                                                                         Oct. 2010
Aviation Technology Solutions
                                                                                                                                                                                                                                                                    15
Part 121 Fine Data Jan 2007 – Sept 2011


                                          Part 121 Cumulative # of Fines
         250


         200


         150


         100


            50


              0
               Jan-07           Aug-07   Mar-08   Oct-08   May-09   Dec-09   Jul-10   Feb-11   Sep-11



Aviation Technology Solutions
                                                                                               16
Certificate Revocation
                                         All Certificate Holders
                                                # of Revocations
                40

                35

                30

                25

                20

                15

                10

                   5

                   0
                                2007     2008          2009        2010   2011



Aviation Technology Solutions
                                                                                 17
Part 145 Fine Data Jan 2007 – Sept 2011
                                                 Fines Levied
                                               Part 145 Fines in $
    $1,000,000.00
      $900,000.00
      $800,000.00
      $700,000.00
      $600,000.00
      $500,000.00
      $400,000.00
      $300,000.00
      $200,000.00
      $100,000.00
              $-
                                Jan-07   Sep-07 May-08   Jan-09   Sep-09 May-10   Jan-11   Sep-11


Aviation Technology Solutions
                                                                                             18
Part 135 Fine Data Jan 2009 – Sept 2011
                                                 Fines Levied

                                                  Part 135 Fines $
      1,600,000
      1,400,000
      1,200,000
      1,000,000
                                                                                  2009 - 119 Actions
           800,000                                                                2010 - 107 Actions
           600,000                                                                2011 - 91 Actions

           400,000
           200,000
                           0
                            Jan-09   Jul-09   Jan-10   Jul-10   Jan-11   Jul-11



Aviation Technology Solutions
                                                                                              19
Course Goals and Objectives


       Understand FAA organization, ASI
        authority, responsibilities and job
        functions.
       Be familiar with hierarchy of FAA
        guidance, including regulations, orders,
        handbooks, etc.
       Learn to navigate FAA policy and
        information via FAA.gov



Aviation Technology Solutions                           19
Course Goals and Objectives


 Be familiar with FAA enforcement and other
  investigative processes
 How to investigate and respond to FAA
  verbal communications and formal Letters of
  Investigation (LOI).
 Understand importance of documenting all
  communications with FAA personnel.




Aviation Technology Solutions                           20
Topics to be Covered

       FAA Processes and Procedures
                        FAA Organization
                        FAA Roles and Responsibilities
                        Operator Information
                        Inspector Job Functions
              Surveillance
              Investigations
              Compliance and Enforcement
              Proactive Approaches
                   “Regulatory Relations”
                   Regulatory Affairs Department


Aviation Technology Solutions                             21
Take Home Knowledge and Skills

     Understand FAA Organization
                 Who to go for what problem
     Understand hierarchy of FAA guidance
                 What’s more important?
                            USC, CFR, AD’s, Orders & handbooks, AC’s, Notices
                            etc. ???
     Understand where to go within FAA information
      databases to research questions
                 Tricks to navigating FAA.gov and other handy sites




Aviation Technology Solutions                                                22
Take Home Knowledge and Skills


             Why are documents so important?
                        Can be both prophylactic and offensive tools
                        Capture data, history is important
             Proactive approaches




Aviation Technology Solutions                                       23
FAA Organization
                                &
                   FAA Processes and Procedures




Aviation Technology Solutions                     24
FAA Organization




Aviation Technology Solutions
                                                    26
                                                   26
                                                    25
Aviation Technology Solutions   26
Aviation Technology Solutions   27
29




Aviation Technology Solutions
                                      29
                                     28
FAA Organization


          FAA Directory




Aviation Technology Solutions
                                                   30
                                                    29
Aviation Technology Solutions   30
Roles and Responsibilities
                                Flight Standards (AFS) Division




Aviation Technology Solutions                                     31
Office of
         Deputy Associate         Rulemaking               Quality,
            Admin. For               ARM                Integration &
         Aviation Safety –                            Executive Service
               AVS-2                                        AQS




        Office of Accident                               Office of Air
         Investigation &         Associate Admin.
                                                       Traffic Oversight
        Prevention - AAI        For Aviation Safety
                                                              AOV
                                       AVS



                                                             Aircraft
        Office of Aerospace                                Certification
              Medicine                                       Service
                AAM             Flight Standards               AIR
                                     Service
                                       AFS


Aviation Technology Solutions                                        32
Resources &
        Gen Aviation &          Program Mgmt       Air Transportation
         Commercial                AFS-100              AFS-200
          AFS-800




        Civil Aviation                                   Aircraft
          Registry                                     Maintenance
          AFS-700               Flight Standards        AFS-300
                                     Service
                                       AFS




                 Regulatory                        Flight Tech and
                  Support                            Procedures
                  AFS-600                              AFS-400


Aviation Technology Solutions                                    33
Roles and Responsibilities of CMO/FSDO

                                            Office hierarchy
                                 Alaska     Responsibilities
        CMO                       CMO         Manger
     Organization
        Chart                                 Assistant Manager
                                Contacts
                                              Supervisors
                                              Principal Inspectors
                                              Assistant PI
                                   MSP        PPMs
          FSDO
                                  FSDO        APMs
       Organization
          Chart                               CSIs
                                Contacts
                                              DEPM
                                              ORA


Aviation Technology Solutions                                         34
Additional Method
                                Employee List FSDO/CMO



                                      FAA.gov may not contain
         Northwest Mtn.                all employee directories
             Region
          Organizations
                                      You can always use
                                       national employee
                                       directory to find someone

                                      How do we get there?

Aviation Technology Solutions                                     35
CMO/FSDO Field Offices




Aviation Technology Solutions                            36
Finding Operator Information




Aviation Technology Solutions                        37
39




Aviation Technology Solutions   3839
Aviation Technology Solutions
                                40
                                 39
Inspector
                                Policies & Procedures

                        Flight Standards Information
                            Management System
                                   (FSIMS)


Aviation Technology Solutions                           40
Inspector Job Functions

    1. Surveillance
       • Most Important/Highest Priority Job Function
    1. Investigations:
       • Accidents, Incidents, Occurrences, Complaints,
          Enforcement
    2. Enforcement – Non-compliance is revealed
    3. Certification – Demand Work/Low Priority
    4. Reports – Documentation of all activities.

                                  FSIMS Table of Contents


Aviation Technology Solutions                               41
Where’s FSIMS?




Aviation Technology Solutions                    42
Inspector Handbook




Aviation Technology Solutions
                                                     44
                                                      43
FAA Order 8900.1




Aviation Technology Solutions
                                                   45
                                                    44
General Information
                                 (FAA Order 8900.1)

       Volume 1
                   Chapter 1: Handbook Organization, Use, and
                    Revision
                     Section 1 : General Handbook Info
                        Paragraph 1-3: Standardization &
                          Coordination
                           C. Conflicts with other FAA Orders
                        Paragraph 1-5
                           A. Directive Information
                           B. Guidance Information

Aviation Technology Solutions                                    45
Inspector Conduct
                                 (FAA Order 8900.1)

     Volume 1
                Chapter 3: Inspector Responsibilities,
                 Administration, Ethics, and Conduct
                           Section 1 : Responsibilities of ASI
                             Paragraph 1-156
                           Section 2: Personal Ethics and Conduct
                             Paragraph 1-176
                                A. Unique Responsibilities of ASI



Aviation Technology Solutions                                        46
Surveillance




Aviation Technology Solutions                  47
Surveillance
                                (FAA Order 8900.1)
 Volume 6
       Chapter 2: Parts 121, 135, and 91 Subpart K
        Inspection
         Section 1: General Policies and Procedures for
          Surveillance
            Paragraphs
              6-165: Introduction
              6-166: Objective of Surveillance Programs
              6-168: Planning and Executing
                Surveillance Programs


Aviation Technology Solutions                        48
Repair Stations Surveillance
                                  (FAA Order 8900.1)

Volume 6




Aviation Technology Solutions
                                                          50
                                                           49
Repair Stations Surveillance
                                           (FAA Order 8900.1)

 Volume 6
       Chapter 13: Enhanced Repair Station Oversight
                   Section 1: Introduction
                                 Paragraph 6-2871
                                    A. Goals, B. Initiatives, D. Components
 Operator Responsibilities
       14 CFR 121.363
 Repair Station Responsibilities
       14 CFR 145.205


 Aviation Technology Solutions                                                 50
Surveillance Conduct
                                            (FAA Order 8900.1)

       Volume 6
                  Chapter 2 Inspections, (14CFR119.59)
                                 Section
                                        3 General Inspection Practices and
                                 Procedures.
                                   Paragraph 6-214: Conducting an Inspection
                                       B. Advance Notice of Inspection
                                       D. Inspector Conduct
                                       E. Concluding inspection




Aviation Technology Solutions                                                   51
Air Transportation Oversight System
                            ATOS Surveillance
                                (FAA Order 8900.1)
 Volume 10
       Chapter 1. General
       Chapter 2. Procedures for Design and Performance
        Assessment
       Chapter 3. Risk Management Process
       Chapter 4. Air Carrier Evaluation Process
       Chapter 5. Off-Hour Surveillance Assessment
        Decision Aid
       Chapter 6. The Certification Process of 121 Air
        Carriers


Aviation Technology Solutions                        52
FAA Order 8900.1
                                      (Formerly ASI Handbook)

 Volume 10
      Chapter 5. Off-Hour Surveillance Assessment
       Decision Aid
                 Section 1
                             Paragraph 10-393
                                A. Identifying and Recording Off-Hour Activity
                                B. Necessity for Additional Off-Hour Surveillance




Aviation Technology Solutions                                                        53
Investigations




Aviation Technology Solutions                    54
Volume 7: Investigations




Aviation Technology Solutions
                                                           56
                                                            55
Volume 7: Investigations

 Chapter 1 Accident & Incident Investigation &
  Reporting
       Section 1 Accident Investigations
                   Paragraph 7-3A: References
                                 FAA order 8020.11 – FAA’s 9 Responsibilities in Accident
                                  Investigations
                   Paragraph 7-4A: Definitions
                                 49 CFR 830.2




 Aviation Technology Solutions                                                       56
Volume 7: Investigations

 Chapter 1 Accident & Incident Investigation &
  Reporting
       Section 2 Incident Investigations and
        Occurrences
                   Paragraph 7-33: Definitions
                                 A, B,C
                   Paragraph 7-34: Responsibilities
                   Paragraph 7-35: Notification




 Aviation Technology Solutions                               57
The FAA Information Highway


                  Hierarchy of Regulations Roadmap

               DocumentsHIERARCHY OF FAA REGULATIONS,
                      ORDERS, NOTICES, etc[1]..doc


                                ROADMAP.doc




Aviation Technology Solutions                            58
Compliance and Enforcement




Aviation Technology Solutions         59
Volume 7: Investigations
                                          (8900.1)
 Chapter 7 Conduct Violation Investigation
       Section 1 General
                   Paragraph 7-223A: General Definitions
                                 Admin, Legal, Airworthy
                   Paragraph 7-225B: Determining Enforceability
                                 Restrictive, Permissive & Types




 Aviation Technology Solutions                                      60
Compliance & Enforcement
                                        (8900.1)

 Volume 14
      Chapter 1: Introduction to Investigation and
       Compliance Related Tasks
                  Section 1 FAA Compliance Philosophy
                                Paragraph 14-1
                                   A. Compliance and Enforcement Differences
                                   B. Relating Compliance and Enforcement to Other
                                    Work Functions.




Aviation Technology Solutions                                                    61
Compliance & Enforcement
                                        (2150.3B)
     Chapter 2 Policy and Objectives
                2a. FAA’s Mission and Authority
                2b. Objective of Compliance and
                 Enforcement Program
     Ultimate Goal is to prevent occurrence of
      violations.
     First priority of FAA investigative personnel
      is to correct ongoing noncompliance.



Aviation Technology Solutions                              62
Compliance & Enforcement
                                         (2150.3B)

     Chapter 2 Continued…
                3d. Notifying Persons of Potential Violations
     Chapter 4: Investigation of Violation
                Applying Findings to Regulations Believed
                 Violated
                           8a. Enforceable Regulations
                           8c. Burden and Standard of Proof
                           8d. Relevance and Materiality        Legal
                                                               Comment




Aviation Technology Solutions                                            63
Compliance & Enforcement
                                        (2150.3B)

 Chapter 4 Continued…
      Paragraph 9: Letter of Investigation and
       Response
                  9a. General
                  9b. Preparation of an LOI
                  9c. Sending the LOI to the Apparent Violator
 Sample LOI




Aviation Technology Solutions                                     64
Compliance & Enforcement
                                         (2150.3B)

 Chapter 4 Continued…
       Paragraph 10: Evidence
                   10c (2): Witness Interviews
                   10c (3): Conducting Interview
 Record of Interview
 Record of Telephone Conversation




 Aviation Technology Solutions                              65
Compliance & Enforcement
                                         (2150.3B)

 Chapter 5: Actions and Responsibilities of FAA
       Paragraph 2: Selection of Enforcement Action
       Paragraph 3: Admin. Action
                   3b. Warning Notice
                   3c. Letter of Correction
       Paragraph 5: Informal Action
       Paragraph 6: Re-inspection & Re-examination
                   Sample Letter Requesting Reexamination



 Aviation Technology Solutions                               66
Compliance & Enforcement
                                         (2150.3B)

 Appendix F. Enforcement Decision Process
       1. Introduction
                   a. Purpose
                   b. EDP Worksheet
       2. Applying the EDP




 Aviation Technology Solutions                              67
Compliance & Enforcement
                                                  (8900.1)

 Applying EDP (continued)
 Volume 14
       Chapter 1: Introduction to Investigation and
        Compliance Related Tasks
                   Section 8: Enforcement Decision Process
                                 EDP worksheet




 Aviation Technology Solutions                                68
Compliance & Enforcement
                                                 (2150.3B)

 Chapter 2: C&E Policy and Objectives
       Paragraph 4: Responsibility for Determining
        Legal Enforcement
                   a. General
                   b. Responsibilities of FAA investigative Personnel
                                 Responsibilities




 Aviation Technology Solutions                                    69
Compliance & Enforcement
                                        (2150.3B)

 Table of Sanctions
      Appendix B
                   Classification of Air carrier
                   Civil Penalty Ranges




Aviation Technology Solutions                              70
Compliance & Enforcement
                                               (8900.1)

 Volume 14
      Chapter 2: C&E Special Considerations
                  Section 1
                                Paragraph 14-158:
                                SNAAP




Aviation Technology Solutions                               71
Responding to Investigations

     How operators should conduct internal
      investigation
     Responding to LOI
     When and how to respond to FAA
                See files from Appendix B & D of SOP
                 Manual
                SOP “B”
                SOP “D”



Aviation Technology Solutions                           72
FAA Order 8900.1
                                      (Formerly ASI Handbook)


 Volume 1 General Guidance and Information
            Chapter 2 FAA and AFS History, Organization,
             and Regulatory Responses
                        Section 2 Title 49, United States Code
                                Paragraph 1-118 Air Carrier Responsibilities for
                                 Public Safety
                                Section 44702(b), 44709, 44713b, of 49 U.S.C




Aviation Technology Solutions                                                 73
Operator Responsibilities
                                    14 CFR 119 & 121

   Regulation 119.59 Conducting Tests and
    inspections
              Certificate holder must
   Regulation 121.135 Manual Contents
              Manual must contain




Aviation Technology Solutions                               74
Operator Responsibilities
                                    Operations Specifications
 14 CFR
          119.43 - Certificate holder’s duty to maintain
           operations specifications
          119.49 – Contents of operations specifications
 Volume 3 General Technical Admin.
          Chapter 18 Operations Specifications
                      Section 1 Background Information
                                Paragraph 3-679; 3-681 Availability of OPSPECS
                                 to Crew members and other employee
                                 personnel.


Aviation Technology Solutions                                               75
Non-Compliance Resolutions

         Threat of Enforcement via OPSPECS
                    119.51 Amending Operations Specifications



                                                     Best
                                                   Practice!




Aviation Technology Solutions                                  76
Pro-Active Solutions




Aviation Technology Solutions                          77
Regulatory Relations




                                 WHO is doing,
                                 WHAT & WHY?




Aviation Technology Solutions                          78
Share Your Worst FAA Inspector
                                 Experience




Aviation Technology Solutions                           79
Reasons not to attack FAA

     Analyze, Learn and GET OVER IT
     Constant state of angst, anxiety and anger
      WILL not allow you to do your job
     FAA gets 51% of vote and is 800lb Gorilla




Aviation Technology Solutions                      80
Reasons not to attack FAA

 Public perception
 Individuals, with whom you are dealing, may
  not accept concept, but regulatory process
  can be cooperative
            Your objective – move to positive relationship




Aviation Technology Solutions                           81
Reasons not to attack FAA

 In your best interest to have relationship that is:
                                Positive,
                                Proactive,
                                Preventative
                                Cooperative

 “I’m OK, You’re OK” Relationship


Aviation Technology Solutions                           82
Positive Regulatory Relationship

 Key attributes for person(s) assigned to be FAA POC:
                  Easy to work with
                  Positive attitude
                  Polite
                  Has ready smile
                  Listens to learn
                  Cool under pressure, maybe having quiet confidence
                  Has firm handshake
                  Makes comfortable eye contact
                  Remembers names
                  Arrives early
                  Follows up consistently, thoughtfully and aggressively


Aviation Technology Solutions
                                                                            84
Who is your FAA Inspector?

                                 Maybe experienced veteran
                                  Listen attentively and learn
                                  More likely to exercise
                                   judgment
                                 More likely
                                  Recent graduate of FAA
                                   Oklahoma City Academy
                                  Has read CFRs at least once
                                  Insecure, yet infallible


Aviation Technology Solutions                                 84
Who is your FAA Inspector?

       Post CSI strict constructionist
       Aware of Oberstar hearings where FAA
        was excoriated
       Principals or manager may not be able to
        control her/him
                   Whistle blower protection
       Not worried at all about what it costs you
        or whether it makes good operational
        sense

                                                 86
Aviation Technology Solutions
Who is your FAA Inspector?
       FAA “administrative ease of
        enforcement/tracking” is actually valid
        criteria
       Truly believes that what they want is
        solely safety driven
       Not evil person, wants to do his/her best
       Understand their agenda



                                                       87
Aviation Technology Solutions
No truth that FAA recruits only from:




Aviation Technology Solutions                      87
Encounter with FAA person

              Who?
              Where from?
              Why here?
              What is agenda?
              What can I do to help?
              What can I learn from this encounter?




                                                            89
Aviation Technology Solutions
Encounter with FAA person

 Who
            First meeting with him/her?
                        Get biz card or ask name and write it down
                        Ask for credentials – “show me your badge”
                        Try to “deflate” situation
                                Ask informal questions (how’s Wx at home;
                                 how was your flight; how many kids do you
                                 have)
                                Make it clear that you are not anxious
                                Move meeting to your turf, quiet place
                                Offer to get coffee, water or soda

                                                                             90
Aviation Technology Solutions
Encounter with FAA Person
       Who Continued 1st meeting
                  Understand his/her authority and interest
                                Inquire why the visit
                                  If enforcement, remember all of “rules” that
                                   you learned during class
                                  If not, listen carefully to what FAA person is
                                   trying to accomplish and LEARN
                                Take good notes
                                  At end of meeting, get concurrence
                                  Action items and IOUs
                                  Set response dates
                                      Meet or exceed them


                                                                                91
Aviation Technology Solutions
More Who Items

       HARD HEADED
          Document it, but do it
          Assign right people
          Keep detailed log
          Make considered decision when to go for the “coup
           de grace”
       My Boss made me do it
          May not just be excuse
          Create legitimate reasons to meet with boss
          Meet boss’ agenda
          Work to reduce friction

Aviation Technology Solutions
                                                               92
Encounter with FAA Person

       Who – had previous meeting
                   Review previous notes
                   Touch on any personal relationships
                    established
                     Kids, sports, interests, work experience
                   Be CERTAIN to reintroduce whatever agenda
                     (office or personal) that you identified before
                                Mention any actions that you have taken or have
                                 initiated along that agenda
                   Follow all ROE mentioned in first encounter


Aviation Technology Solutions
                                                                                   93
Encounter with FAA Person

       Where from
                   If you do not know where from, ask
                   Remember organizational chart lessons:
                                If from DC (AVS, AFS,AIR, etc.)
                                    Person has specific job scope (ask)
                                    Inquiry is VERY likely to be on policy
                                If from your region or another region
                                    Ask about job scope/focus
                                    May be special inquiry/investigation
                                        If it is, should have called for appointment – mention/ask
                                    If from your CMO/FSDO
                                        Could be routine
                                        Ask!!!




Aviation Technology Solutions
                                                                                                      94
Why Here/What is Agenda?

         IMMEDIATELY assess agenda
         Is there enforcement investigation open?
                     If answer is YES, then
                                Questions you should ask yourself…
                                BE CAREFUL WHAT YOU SAY
                                Take comprehensive notes
                     If answer is NO,
                                Opportunity to refine/improve relationship
                                Know their agenda and specific hot buttons




Aviation Technology Solutions
                                                                              95
What can I do to help


       Positive, responsive attitude buys GOODWILL
                   It helps to have “salesperson’s” skill set
                   Seemingly stupid questions do not necessarily mean
                    FAA bad attitude, may just reflect lack of knowledge
                    about real world of operators
                   Take initiative; suggest solutions that BOTH
                                 Make good operational sense
                                 Meets FAA, office and person’s agenda
                                 YOU ARE INFINITELY MORE LIKELY TO DISCERN SUCH
                                  OPTIONS




Aviation Technology Solutions
                                                                                   96
What Can I Do To Help

           If FAA person makes 1st suggestion, you will
            have to “argue” away from that point
           Set deadlines, at least meet them; hopefully
            exceed them
           Try to say “NO” in positive response such as,
                                I’d like to get you those documents, but let’s
                                 consider two options
                                      Someone from my shop will make copies and have them
                                       ready by 3pm in two work days
                                      I can have books available for you to copy by 4pm
                                       today?


Aviation Technology Solutions
                                                                                           96
What Can I Learn From Encounter?


       One approach does not fit all
       Document, Document, Document
                   Sloppy, inaccurate records = blood in water for
                    investigators
                   Maintained, well organized records lead to
                    inspector boredom and case closure
                   The ultimate in FAA “administrative ease”
                   Make their job easy and...




Aviation Technology Solutions
                                                                  98
What Can I Learn From This Encounter?


       Specific Reactions
                  May be headache to adjust
                  Need to do calculus– short term pain v.
                   long term peace
                  Do NOT compromise PRINCIPLES




Aviation Technology Solutions
                                                             99
What Can I Learn From This Encounter?

       Review/ Revise Regulatory Action Plan
        based on each encounter
       Soon after encounter
                   Write report about substance and person(s) involved
                   Soon afterwards is important
                                Subtle messages/signs will be FRESH and mean more
                                    Facial expression may hint whether request is demand or nice-
                                     to-have
                                    Place specific request in context of entire conversation
                   Brief your management
                   Send actions/IOUs and report to FAA for confirmation


Aviation Technology Solutions
                                                                                               100
What Can I Learn From This Encounter?




        FOLLOW UP; convey that FAA agenda is
          matter of importance to company




Aviation Technology Solutions
                                          101
Positive Regulatory Relations

         Set own FAA agenda – proactive not
          reactive
                    Improve records/systems
                    Incorporate specific hot buttons
                    Tell PMI or POI about scheduled company
                     enhancements of non-regulatory systems
                    Share with FAA future commercial
                     developments
                    Create reasons to bolster relations with
                     FSDO, region, HQ leaders

Aviation Technology Solutions
                                                                102
Positive Regulatory Relations, p.2

     Conduct regular Meetings with FAA
                Meet with FSDO or CMO manager monthly
                Exchange info– LISTEN and LEARN
     Follow what’s going on in their world and be
      sensitive
                FAA budget likely to be cut
                Fed pay likely to be frozen
                Congressional hearings



Aviation Technology Solutions
                                                         103
Positive Regulatory Relations, p3
   Get intelligence on FAA trends/issues from your Washington
    Office, Trade Association or legal counsel
      Interpret what appointments mean
      Use as reasons to keep in contact with FAA senior
       leadership
   Create “safety net” for when bad things happen
      Too late to create positive relationship when major
       problem is announced
      Every bit as importantas preventative maintenance
      Use valid reason as predicates for meetings
   Ask your Washington office/trade group to include you in
    meetings with Hill staff (members only if your staff says it is a
    great idea)


Aviation Technology Solutions
                                                                 104
Refresh your Regulatory Relations

                 Not static plan
                 Periodically review relationships, goals and
                  plans
                 Do not get overconfident
                 Equal weight to other operational plans
                 Choose staff with the right skills
                            Make position to be predicate to future promotion
                             within organization



Aviation Technology Solutions                                                104
Establish Regulatory Affairs Group

                 Centralize Reg. Affairs activity
                 Locate office for FAA convenience/access
                 Put under Safety maybe legal
                 Head by MD
                 SOP
                 Train staff
                 Processes, procedures, forms
                 Collect data
                 Coordinate responses as focal point


Aviation Technology Solutions                            105
Establish Positive Relationship


                 Make FAA Agenda Your Priorities
                 Pay attention to FAA local agenda
                 Don’t compromise if your are rock solid certain
                 Look for opportunities to involve FAA early
                 Non-crisis meetings
                 Have regular meetings or CCs
                 Know your PI
                 Learn their Goals and Objectives
                 Go beyond local FAA but keep local in loop


Aviation Technology Solutions                                106
Improve Your Regulatory Knowledge
             Use tools from course
                               Go Beyond FAR
                                 Preamble, NPRM and FR comments
                                 ACs’, 8900.1, AD’s and associated references
                                 Contact FAA POC/author
             Raising the Bar
                         Keep it generic – no dispute
                         Keep records of research, calls - details
                FAA Buddy System
                                Control access, have sign in
                                Escort
                                Document visit, documents copied, questions
                                Document visit and actions
                                SOP with all line stations
                               Follow up email/call confirming actions/dates

Aviation Technology Solutions                                                    107
Outcome


         Proactive business approach not reactive
         Standard approach for FAA interface
         Fewer fines and LOIs
         Improved FAA relationships
         Positive impact on corporate/safety culture
         Improved record keeping
         Less crisis management
         Lower operating costs


Aviation Technology Solutions                       108
After the Course

         Questions about Course Material?
                    Contact instructors by email or phone

         Need Support with FAA Issue or LOI?
            JDA monthly subscription service or on
                                demand/by the drink
                                   Tailored to company size
                                   Former FAA assigned as rep/assist
                                   Lessons learned
                                   Call JDA at 301-941-1460 ext 140 for details or
                                    email JDA at info@jdasolutions.aero



Aviation Technology Solutions                                                         109
Summary and Feedback




Aviation Technology Solutions                          110
Evaluation Forms and Certificates




Aviation Technology Solutions              111
4720 Montgomery Lane
                                      Suite 950
                                 Bethesda, MD 20814
                                www.jdasolutions.aero
                                    301-941-1460



Aviation Technology Solutions                           112

More Related Content

What's hot (16)

Aircraft Certification and Type of Certificates 3-9-13
Aircraft Certification and Type of Certificates 3-9-13Aircraft Certification and Type of Certificates 3-9-13
Aircraft Certification and Type of Certificates 3-9-13
 
Gates cms
Gates cmsGates cms
Gates cms
 
Aircraft maintenance and manuals week 2
Aircraft maintenance and manuals week 2Aircraft maintenance and manuals week 2
Aircraft maintenance and manuals week 2
 
Aircraft Maintenance Documentation
Aircraft Maintenance DocumentationAircraft Maintenance Documentation
Aircraft Maintenance Documentation
 
Aircraft Inspection and Maintenance Records
Aircraft Inspection and Maintenance RecordsAircraft Inspection and Maintenance Records
Aircraft Inspection and Maintenance Records
 
Media Object File Flt Ops Gen Seq01
Media Object File Flt Ops Gen Seq01Media Object File Flt Ops Gen Seq01
Media Object File Flt Ops Gen Seq01
 
Why RCM Doesn\'t Work
Why RCM Doesn\'t WorkWhy RCM Doesn\'t Work
Why RCM Doesn\'t Work
 
Airworthiness: Preventive Maintenance
Airworthiness:  Preventive MaintenanceAirworthiness:  Preventive Maintenance
Airworthiness: Preventive Maintenance
 
Pilot’s Airworthiness Responsibilities
Pilot’s Airworthiness ResponsibilitiesPilot’s Airworthiness Responsibilities
Pilot’s Airworthiness Responsibilities
 
Media Object File Flt Ops Toff Dep Seq04
Media Object File Flt Ops Toff Dep Seq04Media Object File Flt Ops Toff Dep Seq04
Media Object File Flt Ops Toff Dep Seq04
 
Informa Airport Operations Brochure
Informa Airport Operations BrochureInforma Airport Operations Brochure
Informa Airport Operations Brochure
 
Top 10 Causes of FATAL General Aviation Accidents
Top 10 Causes of FATAL General Aviation AccidentsTop 10 Causes of FATAL General Aviation Accidents
Top 10 Causes of FATAL General Aviation Accidents
 
Aircraft inspections
Aircraft inspectionsAircraft inspections
Aircraft inspections
 
Ndt 1
Ndt 1Ndt 1
Ndt 1
 
What to Expect From your Mechanic
What to Expect From your MechanicWhat to Expect From your Mechanic
What to Expect From your Mechanic
 
Aged aircraft maintenance.
Aged aircraft maintenance.Aged aircraft maintenance.
Aged aircraft maintenance.
 

Viewers also liked

Regulatory Affairs.
Regulatory Affairs.Regulatory Affairs.
Regulatory Affairs.Naila Kanwal
 
Pharma regulatory affairs
Pharma regulatory affairsPharma regulatory affairs
Pharma regulatory affairsGirish Swami
 
Regulatory Framework: SOPs For Ethical Regulation Of Drugs
Regulatory Framework: SOPs For Ethical Regulation Of DrugsRegulatory Framework: SOPs For Ethical Regulation Of Drugs
Regulatory Framework: SOPs For Ethical Regulation Of Drugsbiinoida
 
International Regulatory Overview 2009 Rev Linkedln
International Regulatory Overview   2009 Rev LinkedlnInternational Regulatory Overview   2009 Rev Linkedln
International Regulatory Overview 2009 Rev LinkedlnMdbio
 
Introduction to Regulatory Affairs - Pauwels Consulting Academy
Introduction to Regulatory Affairs  - Pauwels Consulting AcademyIntroduction to Regulatory Affairs  - Pauwels Consulting Academy
Introduction to Regulatory Affairs - Pauwels Consulting AcademyPauwels Consulting
 
Brief Self-introduction
Brief Self-introductionBrief Self-introduction
Brief Self-introductionJason Zhang
 
Standard operating procedure for CTA
Standard operating procedure for CTAStandard operating procedure for CTA
Standard operating procedure for CTADr.RAJEEV KASHYAP
 
Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...
Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...
Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...Best Practices
 
Self Introduction
Self IntroductionSelf Introduction
Self Introductionnaomi
 
Regulatory Affairs: Department Models and Structures
Regulatory Affairs: Department Models and StructuresRegulatory Affairs: Department Models and Structures
Regulatory Affairs: Department Models and StructuresIndustry Standard Research
 
Self introduction
Self introductionSelf introduction
Self introductionvickivicki
 
Self Introduction
Self IntroductionSelf Introduction
Self IntroductionJack Feng
 
Top 8 regulatory affairs assistant resume samples
Top 8 regulatory affairs assistant resume samplesTop 8 regulatory affairs assistant resume samples
Top 8 regulatory affairs assistant resume samplesfionabeckie8
 
My self-introduction
My self-introductionMy self-introduction
My self-introductionLyla Chen
 

Viewers also liked (20)

Regulatory Affairs.
Regulatory Affairs.Regulatory Affairs.
Regulatory Affairs.
 
Pharma regulatory affairs
Pharma regulatory affairsPharma regulatory affairs
Pharma regulatory affairs
 
Nutrition Labeling & Claims Vietnam 2012
Nutrition Labeling & Claims Vietnam 2012Nutrition Labeling & Claims Vietnam 2012
Nutrition Labeling & Claims Vietnam 2012
 
Regulatory Framework: SOPs For Ethical Regulation Of Drugs
Regulatory Framework: SOPs For Ethical Regulation Of DrugsRegulatory Framework: SOPs For Ethical Regulation Of Drugs
Regulatory Framework: SOPs For Ethical Regulation Of Drugs
 
International Regulatory Overview 2009 Rev Linkedln
International Regulatory Overview   2009 Rev LinkedlnInternational Regulatory Overview   2009 Rev Linkedln
International Regulatory Overview 2009 Rev Linkedln
 
Current status of nutrition & health claims in vietnam
Current status of nutrition & health claims in vietnamCurrent status of nutrition & health claims in vietnam
Current status of nutrition & health claims in vietnam
 
Introduction to Regulatory Affairs - Pauwels Consulting Academy
Introduction to Regulatory Affairs  - Pauwels Consulting AcademyIntroduction to Regulatory Affairs  - Pauwels Consulting Academy
Introduction to Regulatory Affairs - Pauwels Consulting Academy
 
Brief Self-introduction
Brief Self-introductionBrief Self-introduction
Brief Self-introduction
 
Standard operating procedure for CTA
Standard operating procedure for CTAStandard operating procedure for CTA
Standard operating procedure for CTA
 
Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...
Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...
Regulatory Affairs Excellence: Staffing and Performance in Medical Device Com...
 
Self introduction
Self introductionSelf introduction
Self introduction
 
Self Introduction
Self IntroductionSelf Introduction
Self Introduction
 
Regulatory affairs
Regulatory affairsRegulatory affairs
Regulatory affairs
 
Regulatory Affairs: Department Models and Structures
Regulatory Affairs: Department Models and StructuresRegulatory Affairs: Department Models and Structures
Regulatory Affairs: Department Models and Structures
 
Quality and Regulatory Affairs
Quality and Regulatory AffairsQuality and Regulatory Affairs
Quality and Regulatory Affairs
 
Self introduction
Self introductionSelf introduction
Self introduction
 
Self Introduction
Self IntroductionSelf Introduction
Self Introduction
 
Top 8 regulatory affairs assistant resume samples
Top 8 regulatory affairs assistant resume samplesTop 8 regulatory affairs assistant resume samples
Top 8 regulatory affairs assistant resume samples
 
My self-introduction
My self-introductionMy self-introduction
My self-introduction
 
Pharmaceutical Regulatory Affairs in Australia - by Youssef El-Nazer & Hamid ...
Pharmaceutical Regulatory Affairs in Australia - by Youssef El-Nazer & Hamid ...Pharmaceutical Regulatory Affairs in Australia - by Youssef El-Nazer & Hamid ...
Pharmaceutical Regulatory Affairs in Australia - by Youssef El-Nazer & Hamid ...
 

Similar to Regulatory Affairs powerpoint_slides 031512

AFIRS presentation 10-07-2014-2
AFIRS presentation 10-07-2014-2AFIRS presentation 10-07-2014-2
AFIRS presentation 10-07-2014-2Richard Hayden
 
2017 Heli-Expo - Helicopter FDM Research.
2017 Heli-Expo - Helicopter FDM Research.2017 Heli-Expo - Helicopter FDM Research.
2017 Heli-Expo - Helicopter FDM Research.IHSTFAA
 
Module 5 13 software management control
Module 5 13 software management controlModule 5 13 software management control
Module 5 13 software management controlJoha Rahman
 
Noise abatement training presentation
Noise abatement training presentationNoise abatement training presentation
Noise abatement training presentationJauwadSyed
 
Asset Integrity Management for purpose-built FPSOs and subsea system facilities
Asset Integrity Management for purpose-built FPSOs and subsea system facilitiesAsset Integrity Management for purpose-built FPSOs and subsea system facilities
Asset Integrity Management for purpose-built FPSOs and subsea system facilitiesAdvisian
 
Ground Processing Affordability for Space Vehicles
Ground Processing Affordability for Space VehiclesGround Processing Affordability for Space Vehicles
Ground Processing Affordability for Space VehiclesJohn Ingalls
 
Avionics System Standards.pdf
Avionics System Standards.pdfAvionics System Standards.pdf
Avionics System Standards.pdfJERANRAI1
 
Strategic Management Case Discussion on Southwest Airline
Strategic Management Case Discussion  on Southwest AirlineStrategic Management Case Discussion  on Southwest Airline
Strategic Management Case Discussion on Southwest AirlineUun Ainurrofiq (Fiq)
 
Fundamentals of reliability engineering and applications part1of3
Fundamentals of reliability engineering and applications part1of3Fundamentals of reliability engineering and applications part1of3
Fundamentals of reliability engineering and applications part1of3ASQ Reliability Division
 
Non-OEM / PMA Components and DER Repairs: Best Practices
Non-OEM / PMA Components and DER Repairs: Best PracticesNon-OEM / PMA Components and DER Repairs: Best Practices
Non-OEM / PMA Components and DER Repairs: Best PracticesATOEvents
 
Elements Of Aircraft Maintenance Reserve Development Iata Mcc
Elements Of Aircraft Maintenance Reserve Development   Iata MccElements Of Aircraft Maintenance Reserve Development   Iata Mcc
Elements Of Aircraft Maintenance Reserve Development Iata Mccspackert
 
Apresentação sobre aviação executiva em ny
Apresentação sobre aviação executiva em nyApresentação sobre aviação executiva em ny
Apresentação sobre aviação executiva em nyEmbraer RI
 
Avionics system Standard
Avionics system StandardAvionics system Standard
Avionics system StandardJeran Rai
 

Similar to Regulatory Affairs powerpoint_slides 031512 (20)

Stall and Spins - Awareness and Avoidance
Stall and Spins - Awareness and AvoidanceStall and Spins - Awareness and Avoidance
Stall and Spins - Awareness and Avoidance
 
135 Pro Aviation Services
135 Pro Aviation Services135 Pro Aviation Services
135 Pro Aviation Services
 
Sport Aviation Safety
Sport Aviation SafetySport Aviation Safety
Sport Aviation Safety
 
14 599
14 59914 599
14 599
 
AFIRS presentation 10-07-2014-2
AFIRS presentation 10-07-2014-2AFIRS presentation 10-07-2014-2
AFIRS presentation 10-07-2014-2
 
2017 Heli-Expo - Helicopter FDM Research.
2017 Heli-Expo - Helicopter FDM Research.2017 Heli-Expo - Helicopter FDM Research.
2017 Heli-Expo - Helicopter FDM Research.
 
Module 5 13 software management control
Module 5 13 software management controlModule 5 13 software management control
Module 5 13 software management control
 
Noise abatement training presentation
Noise abatement training presentationNoise abatement training presentation
Noise abatement training presentation
 
Asset Integrity Management for purpose-built FPSOs and subsea system facilities
Asset Integrity Management for purpose-built FPSOs and subsea system facilitiesAsset Integrity Management for purpose-built FPSOs and subsea system facilities
Asset Integrity Management for purpose-built FPSOs and subsea system facilities
 
Ground Processing Affordability for Space Vehicles
Ground Processing Affordability for Space VehiclesGround Processing Affordability for Space Vehicles
Ground Processing Affordability for Space Vehicles
 
Avionics System Standards.pdf
Avionics System Standards.pdfAvionics System Standards.pdf
Avionics System Standards.pdf
 
Strategic Management Case Discussion on Southwest Airline
Strategic Management Case Discussion  on Southwest AirlineStrategic Management Case Discussion  on Southwest Airline
Strategic Management Case Discussion on Southwest Airline
 
Fundamentals of reliability engineering and applications part1of3
Fundamentals of reliability engineering and applications part1of3Fundamentals of reliability engineering and applications part1of3
Fundamentals of reliability engineering and applications part1of3
 
Non-OEM / PMA Components and DER Repairs: Best Practices
Non-OEM / PMA Components and DER Repairs: Best PracticesNon-OEM / PMA Components and DER Repairs: Best Practices
Non-OEM / PMA Components and DER Repairs: Best Practices
 
Aircraft modifications 3-9-2013
Aircraft modifications 3-9-2013Aircraft modifications 3-9-2013
Aircraft modifications 3-9-2013
 
Elements Of Aircraft Maintenance Reserve Development Iata Mcc
Elements Of Aircraft Maintenance Reserve Development   Iata MccElements Of Aircraft Maintenance Reserve Development   Iata Mcc
Elements Of Aircraft Maintenance Reserve Development Iata Mcc
 
Apresentação sobre aviação executiva em ny
Apresentação sobre aviação executiva em nyApresentação sobre aviação executiva em ny
Apresentação sobre aviação executiva em ny
 
Avionics System Standards
Avionics System StandardsAvionics System Standards
Avionics System Standards
 
Avionics system Standard
Avionics system StandardAvionics system Standard
Avionics system Standard
 
Upset Prevention and Recovery
Upset Prevention and RecoveryUpset Prevention and Recovery
Upset Prevention and Recovery
 

More from JDA Aviation Technology Solutions (10)

Au presentation
Au presentationAu presentation
Au presentation
 
SMS - Safety Management Systems
SMS - Safety Management SystemsSMS - Safety Management Systems
SMS - Safety Management Systems
 
Tedsbox presentation
Tedsbox presentationTedsbox presentation
Tedsbox presentation
 
The Head Guard
The Head GuardThe Head Guard
The Head Guard
 
Airport SMS
Airport SMSAirport SMS
Airport SMS
 
SMS Pro
SMS ProSMS Pro
SMS Pro
 
VRCom Operational Control
VRCom Operational ControlVRCom Operational Control
VRCom Operational Control
 
Food Industry Safety
Food Industry SafetyFood Industry Safety
Food Industry Safety
 
SMS and Healthcare - Reducing Medical Errors
SMS and Healthcare - Reducing Medical ErrorsSMS and Healthcare - Reducing Medical Errors
SMS and Healthcare - Reducing Medical Errors
 
Jda foqa briefing slide view
Jda foqa briefing slide viewJda foqa briefing slide view
Jda foqa briefing slide view
 

Recently uploaded

Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...
Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...
Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...Dave Litwiller
 
RE Capital's Visionary Leadership under Newman Leech
RE Capital's Visionary Leadership under Newman LeechRE Capital's Visionary Leadership under Newman Leech
RE Capital's Visionary Leadership under Newman LeechNewman George Leech
 
Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...
Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...
Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...lizamodels9
 
0183760ssssssssssssssssssssssssssss00101011 (27).pdf
0183760ssssssssssssssssssssssssssss00101011 (27).pdf0183760ssssssssssssssssssssssssssss00101011 (27).pdf
0183760ssssssssssssssssssssssssssss00101011 (27).pdfRenandantas16
 
Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...
Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...
Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...Lviv Startup Club
 
Sales & Marketing Alignment: How to Synergize for Success
Sales & Marketing Alignment: How to Synergize for SuccessSales & Marketing Alignment: How to Synergize for Success
Sales & Marketing Alignment: How to Synergize for SuccessAggregage
 
A DAY IN THE LIFE OF A SALESMAN / WOMAN
A DAY IN THE LIFE OF A  SALESMAN / WOMANA DAY IN THE LIFE OF A  SALESMAN / WOMAN
A DAY IN THE LIFE OF A SALESMAN / WOMANIlamathiKannappan
 
7.pdf This presentation captures many uses and the significance of the number...
7.pdf This presentation captures many uses and the significance of the number...7.pdf This presentation captures many uses and the significance of the number...
7.pdf This presentation captures many uses and the significance of the number...Paul Menig
 
Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...Dipal Arora
 
Grateful 7 speech thanking everyone that has helped.pdf
Grateful 7 speech thanking everyone that has helped.pdfGrateful 7 speech thanking everyone that has helped.pdf
Grateful 7 speech thanking everyone that has helped.pdfPaul Menig
 
M.C Lodges -- Guest House in Jhang.
M.C Lodges --  Guest House in Jhang.M.C Lodges --  Guest House in Jhang.
M.C Lodges -- Guest House in Jhang.Aaiza Hassan
 
BEST ✨ Call Girls In Indirapuram Ghaziabad ✔️ 9871031762 ✔️ Escorts Service...
BEST ✨ Call Girls In  Indirapuram Ghaziabad  ✔️ 9871031762 ✔️ Escorts Service...BEST ✨ Call Girls In  Indirapuram Ghaziabad  ✔️ 9871031762 ✔️ Escorts Service...
BEST ✨ Call Girls In Indirapuram Ghaziabad ✔️ 9871031762 ✔️ Escorts Service...noida100girls
 
Creating Low-Code Loan Applications using the Trisotech Mortgage Feature Set
Creating Low-Code Loan Applications using the Trisotech Mortgage Feature SetCreating Low-Code Loan Applications using the Trisotech Mortgage Feature Set
Creating Low-Code Loan Applications using the Trisotech Mortgage Feature SetDenis Gagné
 
The Coffee Bean & Tea Leaf(CBTL), Business strategy case study
The Coffee Bean & Tea Leaf(CBTL), Business strategy case studyThe Coffee Bean & Tea Leaf(CBTL), Business strategy case study
The Coffee Bean & Tea Leaf(CBTL), Business strategy case studyEthan lee
 
The CMO Survey - Highlights and Insights Report - Spring 2024
The CMO Survey - Highlights and Insights Report - Spring 2024The CMO Survey - Highlights and Insights Report - Spring 2024
The CMO Survey - Highlights and Insights Report - Spring 2024christinemoorman
 
Cash Payment 9602870969 Escort Service in Udaipur Call Girls
Cash Payment 9602870969 Escort Service in Udaipur Call GirlsCash Payment 9602870969 Escort Service in Udaipur Call Girls
Cash Payment 9602870969 Escort Service in Udaipur Call GirlsApsara Of India
 
Insurers' journeys to build a mastery in the IoT usage
Insurers' journeys to build a mastery in the IoT usageInsurers' journeys to build a mastery in the IoT usage
Insurers' journeys to build a mastery in the IoT usageMatteo Carbone
 

Recently uploaded (20)

Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...
Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...
Enhancing and Restoring Safety & Quality Cultures - Dave Litwiller - May 2024...
 
RE Capital's Visionary Leadership under Newman Leech
RE Capital's Visionary Leadership under Newman LeechRE Capital's Visionary Leadership under Newman Leech
RE Capital's Visionary Leadership under Newman Leech
 
Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...
Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...
Call Girls In DLf Gurgaon ➥99902@11544 ( Best price)100% Genuine Escort In 24...
 
0183760ssssssssssssssssssssssssssss00101011 (27).pdf
0183760ssssssssssssssssssssssssssss00101011 (27).pdf0183760ssssssssssssssssssssssssssss00101011 (27).pdf
0183760ssssssssssssssssssssssssssss00101011 (27).pdf
 
Nepali Escort Girl Kakori \ 9548273370 Indian Call Girls Service Lucknow ₹,9517
Nepali Escort Girl Kakori \ 9548273370 Indian Call Girls Service Lucknow ₹,9517Nepali Escort Girl Kakori \ 9548273370 Indian Call Girls Service Lucknow ₹,9517
Nepali Escort Girl Kakori \ 9548273370 Indian Call Girls Service Lucknow ₹,9517
 
Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...
Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...
Yaroslav Rozhankivskyy: Три складові і три передумови максимальної продуктивн...
 
Sales & Marketing Alignment: How to Synergize for Success
Sales & Marketing Alignment: How to Synergize for SuccessSales & Marketing Alignment: How to Synergize for Success
Sales & Marketing Alignment: How to Synergize for Success
 
A DAY IN THE LIFE OF A SALESMAN / WOMAN
A DAY IN THE LIFE OF A  SALESMAN / WOMANA DAY IN THE LIFE OF A  SALESMAN / WOMAN
A DAY IN THE LIFE OF A SALESMAN / WOMAN
 
Best Practices for Implementing an External Recruiting Partnership
Best Practices for Implementing an External Recruiting PartnershipBest Practices for Implementing an External Recruiting Partnership
Best Practices for Implementing an External Recruiting Partnership
 
7.pdf This presentation captures many uses and the significance of the number...
7.pdf This presentation captures many uses and the significance of the number...7.pdf This presentation captures many uses and the significance of the number...
7.pdf This presentation captures many uses and the significance of the number...
 
Forklift Operations: Safety through Cartoons
Forklift Operations: Safety through CartoonsForklift Operations: Safety through Cartoons
Forklift Operations: Safety through Cartoons
 
Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Navi Mumbai Just Call 9907093804 Top Class Call Girl Service Avail...
 
Grateful 7 speech thanking everyone that has helped.pdf
Grateful 7 speech thanking everyone that has helped.pdfGrateful 7 speech thanking everyone that has helped.pdf
Grateful 7 speech thanking everyone that has helped.pdf
 
M.C Lodges -- Guest House in Jhang.
M.C Lodges --  Guest House in Jhang.M.C Lodges --  Guest House in Jhang.
M.C Lodges -- Guest House in Jhang.
 
BEST ✨ Call Girls In Indirapuram Ghaziabad ✔️ 9871031762 ✔️ Escorts Service...
BEST ✨ Call Girls In  Indirapuram Ghaziabad  ✔️ 9871031762 ✔️ Escorts Service...BEST ✨ Call Girls In  Indirapuram Ghaziabad  ✔️ 9871031762 ✔️ Escorts Service...
BEST ✨ Call Girls In Indirapuram Ghaziabad ✔️ 9871031762 ✔️ Escorts Service...
 
Creating Low-Code Loan Applications using the Trisotech Mortgage Feature Set
Creating Low-Code Loan Applications using the Trisotech Mortgage Feature SetCreating Low-Code Loan Applications using the Trisotech Mortgage Feature Set
Creating Low-Code Loan Applications using the Trisotech Mortgage Feature Set
 
The Coffee Bean & Tea Leaf(CBTL), Business strategy case study
The Coffee Bean & Tea Leaf(CBTL), Business strategy case studyThe Coffee Bean & Tea Leaf(CBTL), Business strategy case study
The Coffee Bean & Tea Leaf(CBTL), Business strategy case study
 
The CMO Survey - Highlights and Insights Report - Spring 2024
The CMO Survey - Highlights and Insights Report - Spring 2024The CMO Survey - Highlights and Insights Report - Spring 2024
The CMO Survey - Highlights and Insights Report - Spring 2024
 
Cash Payment 9602870969 Escort Service in Udaipur Call Girls
Cash Payment 9602870969 Escort Service in Udaipur Call GirlsCash Payment 9602870969 Escort Service in Udaipur Call Girls
Cash Payment 9602870969 Escort Service in Udaipur Call Girls
 
Insurers' journeys to build a mastery in the IoT usage
Insurers' journeys to build a mastery in the IoT usageInsurers' journeys to build a mastery in the IoT usage
Insurers' journeys to build a mastery in the IoT usage
 

Regulatory Affairs powerpoint_slides 031512

  • 1. Regulatory Affairs Training FAA Relations Aviation Technology Solutions 1
  • 2. Program 1. Introductions and Expectations 2. JDA Background 3. Current Operating Environment 4. Goals and Objectives 5. FAA Processes and Procedures 6. Pro Active Solutions 7. Summary and Feedback Aviation Technology Solutions 2
  • 3. Introductions and Expectations  Briefly state name and responsibilities  Please share your expectations for course  Please share example of FAA interface/confrontation  Additional “war stories” during course welcome – limit to 2 minutes please Aviation Technology Solutions 3
  • 5. Current Operating Environment  Lawmakers Outraged by FAA Safety Violations  House Transportation & Infrastructure Hearing  April 3, 2008  Operators are no longer FAA customers  Whistleblowers are heroes  New Office under Chief Counsel (AAE)  CMO/FSDO Standardization - GAO Report  “Informal” Field Station Visit Results Aviation Technology Solutions 5
  • 6. Current and Future Operating Environment  Regulatory Compliance Environment  Evolution of Surveillance/Oversight Process  Air Transportation Oversight System (ATOS)  Part 121  System Approach for Safety Oversight (SASO)  Parts 121, 135, 145  Deploy in 2103 Aviation Technology Solutions 6
  • 7. Current and Future Operating Environment  Safety Management System (SMS)  Parts 121, 139 Final Rule NLT Oct 2012  Other Certificated Operators 135, 145 TBD  New Entrant 121 operators  Must include SMS as part of formal application  SAS will provide oversight function and aligned with SMS to ensure AFS “SAS” Safety Assurance System Aviation Technology Solutions 7
  • 8. Key FAA HQ Management Michael Huerta Acting FAA Administrator Peggy Gilligan Associate Administrator for Aviation Safety John Allen Director Flight Standards Service Aviation Technology Solutions 8
  • 11. Record Fines FAA • Already collected twice as much in fines then in final two years of Bush presidency. • Fines are weighing on carriers that recently reported first collective profit in 2 1/2 years. “The pendulum has swung pretty hard.’’ •Levied $4.77 million in penalties since Obama took office, 84% percent jump from 2007-2008. • Proposed $77.4 million in fines 9/09 – 9/10 up 66 percent from 9/07-9/08. Aviation Technology Solutions 11
  • 12. Significant Proposed Fines 2011 Part 121 Operator Type Date Proposed Fine Alleged Violation Horizon Air 121 12/09/11 $777,000 Maintenance non compliance Evergreen Air 121 11/11/11 $180,000 Operations non Compliance Skywest 121 10/21/11 $160,000 Maintenance non compliance Pinnacle 121 10/21/11 $1,000,000 Maintenance non compliance Colgan Airlines 121 09/15/11 $1,892,000 Operations non Compliance Alaska Airlines 121 09/09/11 $590,000 Maintenance non compliance Capital Cargo 121 08/29/11 $298,500 Maintenance non compliance American Eagle 121 08/10/11 $155,000 Operations non Compliance American Eagle 121 07/11/11 $77,500 Maintenance non compliance Atlantic Southeast 121 07/11/11 $132,000 Maintenance non compliance Federal Express 121 07/08/11 $689,800 Operations non Compliance Air Tran 121 06/23/11 $250,000 Maintenance non compliance United Airlines 121 06/17/11 $584,375 Operations non Compliance Atlantic Southeast 121 06/16/11 $425,000 Maintenance non compliance Lynx Aviation 121 04/08/11 $350,000 Maintenance non compliance Executive Airlines 121 03/30/11 $550,000 Maintenance non compliance Skywest 121 01/18/11 $359,000 Ops and Maint non Compliance Total Proposed 121 $8,470,175 Aviation Technology Solutions 12
  • 13. Significant Proposed Fines 2011 Part 145 and 135 and Manufacturers Streamline Aviation 145 10/21/11 $241,200 Maintenance non compliance Aviaton Technical Services 145 09/12/11 $1,100,000 Maintenance non compliance Aviation Specialities 145 07/11/11 $77,000 Maintenance non compliance Jet Aircraft Miami 145 07/11/11 $66,000 Maintenance non compliance Pemco World Aviation Svcs 145 01/21/11 $170,000 Operations non Compliance San Antonio Aerospace 145 01/20/11 $1,025,000 Operations non Compliance Total Proposed 145 $2,679,200 Parachute Center 135 08/29/11 $269,000 Maintenance non compliance Ameriflight 135 08/26/11 $262,000 Operations Non Compliance Liberty Jet 135 07/11/11 $75,000 Operations Non Compliance Apollo Aviation 135 07/11/11 $77,300 Maintenance non compliance Jet Smart 135 07/11/11 $133,900 Maintenance non compliance 26 North Aviation 135 07/11/11 $81,000 Maintenance non compliance Bimini Island Air 135 07/11/11 Certificate Revocation Regulatory Violation ERA Helicopters 135 07/08/11 $194,249 Operations Non Compliance Corporate Air 135 02/17/11 $585,275 Maintenance non compliance Heli-Dudes* 135 01/06/11 $330,000 Regulatory Violation Total Proposed 135 $2,007,724 Cessna Manufacturer 09/22/11 $2,400,000 Manufacturing Process Boeing Manufacturer 06/27/11 $1,050,000 Regulatory Violation Total Proposed Mfg $3,450,000 Aviation Technology Solutions 13
  • 14. Part 121 Fine Data Jan 2007 – Sept 2011 Fines Levied Part 121 Cumulative Fines in $ $14,000,000.00 $12,000,000.00 $10,000,000.00 $8,000,000.00 $6,000,000.00 $4,000,000.00 $2,000,000.00 $- Jul. 2007 Jul. 2008 Jul. 2009 Jul. 2010 Jul. 2011 Apr. 2007 Apr. 2008 Apr. 2009 Apr. 2010 Apr. 2011 Jan. 2007 Jan. 2008 Jan. 2009 Jan. 2010 Jan. 2011 Oct. 2007 Oct. 2008 Oct. 2009 Oct. 2010 Aviation Technology Solutions 15
  • 15. Part 121 Fine Data Jan 2007 – Sept 2011 Part 121 Cumulative # of Fines 250 200 150 100 50 0 Jan-07 Aug-07 Mar-08 Oct-08 May-09 Dec-09 Jul-10 Feb-11 Sep-11 Aviation Technology Solutions 16
  • 16. Certificate Revocation All Certificate Holders # of Revocations 40 35 30 25 20 15 10 5 0 2007 2008 2009 2010 2011 Aviation Technology Solutions 17
  • 17. Part 145 Fine Data Jan 2007 – Sept 2011 Fines Levied Part 145 Fines in $ $1,000,000.00 $900,000.00 $800,000.00 $700,000.00 $600,000.00 $500,000.00 $400,000.00 $300,000.00 $200,000.00 $100,000.00 $- Jan-07 Sep-07 May-08 Jan-09 Sep-09 May-10 Jan-11 Sep-11 Aviation Technology Solutions 18
  • 18. Part 135 Fine Data Jan 2009 – Sept 2011 Fines Levied Part 135 Fines $ 1,600,000 1,400,000 1,200,000 1,000,000 2009 - 119 Actions 800,000 2010 - 107 Actions 600,000 2011 - 91 Actions 400,000 200,000 0 Jan-09 Jul-09 Jan-10 Jul-10 Jan-11 Jul-11 Aviation Technology Solutions 19
  • 19. Course Goals and Objectives  Understand FAA organization, ASI authority, responsibilities and job functions.  Be familiar with hierarchy of FAA guidance, including regulations, orders, handbooks, etc.  Learn to navigate FAA policy and information via FAA.gov Aviation Technology Solutions 19
  • 20. Course Goals and Objectives  Be familiar with FAA enforcement and other investigative processes  How to investigate and respond to FAA verbal communications and formal Letters of Investigation (LOI).  Understand importance of documenting all communications with FAA personnel. Aviation Technology Solutions 20
  • 21. Topics to be Covered  FAA Processes and Procedures  FAA Organization  FAA Roles and Responsibilities  Operator Information  Inspector Job Functions  Surveillance  Investigations  Compliance and Enforcement  Proactive Approaches  “Regulatory Relations”  Regulatory Affairs Department Aviation Technology Solutions 21
  • 22. Take Home Knowledge and Skills  Understand FAA Organization  Who to go for what problem  Understand hierarchy of FAA guidance  What’s more important?  USC, CFR, AD’s, Orders & handbooks, AC’s, Notices etc. ???  Understand where to go within FAA information databases to research questions  Tricks to navigating FAA.gov and other handy sites Aviation Technology Solutions 22
  • 23. Take Home Knowledge and Skills  Why are documents so important? Can be both prophylactic and offensive tools Capture data, history is important  Proactive approaches Aviation Technology Solutions 23
  • 24. FAA Organization & FAA Processes and Procedures Aviation Technology Solutions 24
  • 29. FAA Organization FAA Directory Aviation Technology Solutions 30 29
  • 31. Roles and Responsibilities Flight Standards (AFS) Division Aviation Technology Solutions 31
  • 32. Office of Deputy Associate Rulemaking Quality, Admin. For ARM Integration & Aviation Safety – Executive Service AVS-2 AQS Office of Accident Office of Air Investigation & Associate Admin. Traffic Oversight Prevention - AAI For Aviation Safety AOV AVS Aircraft Office of Aerospace Certification Medicine Service AAM Flight Standards AIR Service AFS Aviation Technology Solutions 32
  • 33. Resources & Gen Aviation & Program Mgmt Air Transportation Commercial AFS-100 AFS-200 AFS-800 Civil Aviation Aircraft Registry Maintenance AFS-700 Flight Standards AFS-300 Service AFS Regulatory Flight Tech and Support Procedures AFS-600 AFS-400 Aviation Technology Solutions 33
  • 34. Roles and Responsibilities of CMO/FSDO  Office hierarchy Alaska  Responsibilities CMO CMO Manger Organization Chart Assistant Manager Contacts Supervisors Principal Inspectors Assistant PI MSP PPMs FSDO FSDO APMs Organization Chart CSIs Contacts DEPM ORA Aviation Technology Solutions 34
  • 35. Additional Method Employee List FSDO/CMO  FAA.gov may not contain Northwest Mtn. all employee directories Region Organizations  You can always use national employee directory to find someone  How do we get there? Aviation Technology Solutions 35
  • 36. CMO/FSDO Field Offices Aviation Technology Solutions 36
  • 37. Finding Operator Information Aviation Technology Solutions 37
  • 40. Inspector Policies & Procedures Flight Standards Information Management System (FSIMS) Aviation Technology Solutions 40
  • 41. Inspector Job Functions 1. Surveillance • Most Important/Highest Priority Job Function 1. Investigations: • Accidents, Incidents, Occurrences, Complaints, Enforcement 2. Enforcement – Non-compliance is revealed 3. Certification – Demand Work/Low Priority 4. Reports – Documentation of all activities. FSIMS Table of Contents Aviation Technology Solutions 41
  • 44. FAA Order 8900.1 Aviation Technology Solutions 45 44
  • 45. General Information (FAA Order 8900.1)  Volume 1  Chapter 1: Handbook Organization, Use, and Revision Section 1 : General Handbook Info Paragraph 1-3: Standardization & Coordination C. Conflicts with other FAA Orders Paragraph 1-5 A. Directive Information B. Guidance Information Aviation Technology Solutions 45
  • 46. Inspector Conduct (FAA Order 8900.1)  Volume 1 Chapter 3: Inspector Responsibilities, Administration, Ethics, and Conduct Section 1 : Responsibilities of ASI Paragraph 1-156 Section 2: Personal Ethics and Conduct Paragraph 1-176 A. Unique Responsibilities of ASI Aviation Technology Solutions 46
  • 48. Surveillance (FAA Order 8900.1)  Volume 6  Chapter 2: Parts 121, 135, and 91 Subpart K Inspection Section 1: General Policies and Procedures for Surveillance Paragraphs 6-165: Introduction 6-166: Objective of Surveillance Programs 6-168: Planning and Executing Surveillance Programs Aviation Technology Solutions 48
  • 49. Repair Stations Surveillance (FAA Order 8900.1) Volume 6 Aviation Technology Solutions 50 49
  • 50. Repair Stations Surveillance (FAA Order 8900.1)  Volume 6 Chapter 13: Enhanced Repair Station Oversight Section 1: Introduction Paragraph 6-2871  A. Goals, B. Initiatives, D. Components  Operator Responsibilities 14 CFR 121.363  Repair Station Responsibilities 14 CFR 145.205 Aviation Technology Solutions 50
  • 51. Surveillance Conduct (FAA Order 8900.1)  Volume 6 Chapter 2 Inspections, (14CFR119.59)  Section 3 General Inspection Practices and Procedures. Paragraph 6-214: Conducting an Inspection  B. Advance Notice of Inspection  D. Inspector Conduct  E. Concluding inspection Aviation Technology Solutions 51
  • 52. Air Transportation Oversight System ATOS Surveillance (FAA Order 8900.1)  Volume 10  Chapter 1. General  Chapter 2. Procedures for Design and Performance Assessment  Chapter 3. Risk Management Process  Chapter 4. Air Carrier Evaluation Process  Chapter 5. Off-Hour Surveillance Assessment Decision Aid  Chapter 6. The Certification Process of 121 Air Carriers Aviation Technology Solutions 52
  • 53. FAA Order 8900.1 (Formerly ASI Handbook)  Volume 10  Chapter 5. Off-Hour Surveillance Assessment Decision Aid  Section 1  Paragraph 10-393 A. Identifying and Recording Off-Hour Activity B. Necessity for Additional Off-Hour Surveillance Aviation Technology Solutions 53
  • 55. Volume 7: Investigations Aviation Technology Solutions 56 55
  • 56. Volume 7: Investigations  Chapter 1 Accident & Incident Investigation & Reporting Section 1 Accident Investigations Paragraph 7-3A: References FAA order 8020.11 – FAA’s 9 Responsibilities in Accident Investigations Paragraph 7-4A: Definitions 49 CFR 830.2 Aviation Technology Solutions 56
  • 57. Volume 7: Investigations  Chapter 1 Accident & Incident Investigation & Reporting Section 2 Incident Investigations and Occurrences Paragraph 7-33: Definitions A, B,C Paragraph 7-34: Responsibilities Paragraph 7-35: Notification Aviation Technology Solutions 57
  • 58. The FAA Information Highway Hierarchy of Regulations Roadmap DocumentsHIERARCHY OF FAA REGULATIONS, ORDERS, NOTICES, etc[1]..doc ROADMAP.doc Aviation Technology Solutions 58
  • 59. Compliance and Enforcement Aviation Technology Solutions 59
  • 60. Volume 7: Investigations (8900.1)  Chapter 7 Conduct Violation Investigation Section 1 General Paragraph 7-223A: General Definitions Admin, Legal, Airworthy Paragraph 7-225B: Determining Enforceability Restrictive, Permissive & Types Aviation Technology Solutions 60
  • 61. Compliance & Enforcement (8900.1)  Volume 14 Chapter 1: Introduction to Investigation and Compliance Related Tasks Section 1 FAA Compliance Philosophy Paragraph 14-1  A. Compliance and Enforcement Differences  B. Relating Compliance and Enforcement to Other Work Functions. Aviation Technology Solutions 61
  • 62. Compliance & Enforcement (2150.3B)  Chapter 2 Policy and Objectives 2a. FAA’s Mission and Authority 2b. Objective of Compliance and Enforcement Program  Ultimate Goal is to prevent occurrence of violations.  First priority of FAA investigative personnel is to correct ongoing noncompliance. Aviation Technology Solutions 62
  • 63. Compliance & Enforcement (2150.3B)  Chapter 2 Continued… 3d. Notifying Persons of Potential Violations  Chapter 4: Investigation of Violation Applying Findings to Regulations Believed Violated 8a. Enforceable Regulations 8c. Burden and Standard of Proof 8d. Relevance and Materiality Legal Comment Aviation Technology Solutions 63
  • 64. Compliance & Enforcement (2150.3B)  Chapter 4 Continued… Paragraph 9: Letter of Investigation and Response 9a. General 9b. Preparation of an LOI 9c. Sending the LOI to the Apparent Violator  Sample LOI Aviation Technology Solutions 64
  • 65. Compliance & Enforcement (2150.3B)  Chapter 4 Continued… Paragraph 10: Evidence 10c (2): Witness Interviews 10c (3): Conducting Interview  Record of Interview  Record of Telephone Conversation Aviation Technology Solutions 65
  • 66. Compliance & Enforcement (2150.3B)  Chapter 5: Actions and Responsibilities of FAA Paragraph 2: Selection of Enforcement Action Paragraph 3: Admin. Action 3b. Warning Notice 3c. Letter of Correction Paragraph 5: Informal Action Paragraph 6: Re-inspection & Re-examination Sample Letter Requesting Reexamination Aviation Technology Solutions 66
  • 67. Compliance & Enforcement (2150.3B)  Appendix F. Enforcement Decision Process 1. Introduction a. Purpose b. EDP Worksheet 2. Applying the EDP Aviation Technology Solutions 67
  • 68. Compliance & Enforcement (8900.1)  Applying EDP (continued)  Volume 14 Chapter 1: Introduction to Investigation and Compliance Related Tasks Section 8: Enforcement Decision Process EDP worksheet Aviation Technology Solutions 68
  • 69. Compliance & Enforcement (2150.3B)  Chapter 2: C&E Policy and Objectives Paragraph 4: Responsibility for Determining Legal Enforcement a. General b. Responsibilities of FAA investigative Personnel Responsibilities Aviation Technology Solutions 69
  • 70. Compliance & Enforcement (2150.3B)  Table of Sanctions Appendix B  Classification of Air carrier  Civil Penalty Ranges Aviation Technology Solutions 70
  • 71. Compliance & Enforcement (8900.1)  Volume 14 Chapter 2: C&E Special Considerations Section 1 Paragraph 14-158: SNAAP Aviation Technology Solutions 71
  • 72. Responding to Investigations  How operators should conduct internal investigation  Responding to LOI  When and how to respond to FAA See files from Appendix B & D of SOP Manual SOP “B” SOP “D” Aviation Technology Solutions 72
  • 73. FAA Order 8900.1 (Formerly ASI Handbook)  Volume 1 General Guidance and Information Chapter 2 FAA and AFS History, Organization, and Regulatory Responses Section 2 Title 49, United States Code Paragraph 1-118 Air Carrier Responsibilities for Public Safety Section 44702(b), 44709, 44713b, of 49 U.S.C Aviation Technology Solutions 73
  • 74. Operator Responsibilities 14 CFR 119 & 121  Regulation 119.59 Conducting Tests and inspections Certificate holder must  Regulation 121.135 Manual Contents Manual must contain Aviation Technology Solutions 74
  • 75. Operator Responsibilities Operations Specifications  14 CFR 119.43 - Certificate holder’s duty to maintain operations specifications 119.49 – Contents of operations specifications  Volume 3 General Technical Admin. Chapter 18 Operations Specifications Section 1 Background Information Paragraph 3-679; 3-681 Availability of OPSPECS to Crew members and other employee personnel. Aviation Technology Solutions 75
  • 76. Non-Compliance Resolutions  Threat of Enforcement via OPSPECS 119.51 Amending Operations Specifications Best Practice! Aviation Technology Solutions 76
  • 78. Regulatory Relations WHO is doing, WHAT & WHY? Aviation Technology Solutions 78
  • 79. Share Your Worst FAA Inspector Experience Aviation Technology Solutions 79
  • 80. Reasons not to attack FAA  Analyze, Learn and GET OVER IT  Constant state of angst, anxiety and anger WILL not allow you to do your job  FAA gets 51% of vote and is 800lb Gorilla Aviation Technology Solutions 80
  • 81. Reasons not to attack FAA  Public perception  Individuals, with whom you are dealing, may not accept concept, but regulatory process can be cooperative  Your objective – move to positive relationship Aviation Technology Solutions 81
  • 82. Reasons not to attack FAA  In your best interest to have relationship that is: Positive, Proactive, Preventative Cooperative  “I’m OK, You’re OK” Relationship Aviation Technology Solutions 82
  • 83. Positive Regulatory Relationship  Key attributes for person(s) assigned to be FAA POC:  Easy to work with  Positive attitude  Polite  Has ready smile  Listens to learn  Cool under pressure, maybe having quiet confidence  Has firm handshake  Makes comfortable eye contact  Remembers names  Arrives early  Follows up consistently, thoughtfully and aggressively Aviation Technology Solutions 84
  • 84. Who is your FAA Inspector?  Maybe experienced veteran Listen attentively and learn More likely to exercise judgment  More likely Recent graduate of FAA Oklahoma City Academy Has read CFRs at least once Insecure, yet infallible Aviation Technology Solutions 84
  • 85. Who is your FAA Inspector?  Post CSI strict constructionist  Aware of Oberstar hearings where FAA was excoriated  Principals or manager may not be able to control her/him  Whistle blower protection  Not worried at all about what it costs you or whether it makes good operational sense 86 Aviation Technology Solutions
  • 86. Who is your FAA Inspector?  FAA “administrative ease of enforcement/tracking” is actually valid criteria  Truly believes that what they want is solely safety driven  Not evil person, wants to do his/her best  Understand their agenda 87 Aviation Technology Solutions
  • 87. No truth that FAA recruits only from: Aviation Technology Solutions 87
  • 88. Encounter with FAA person  Who?  Where from?  Why here?  What is agenda?  What can I do to help?  What can I learn from this encounter? 89 Aviation Technology Solutions
  • 89. Encounter with FAA person  Who First meeting with him/her? Get biz card or ask name and write it down Ask for credentials – “show me your badge” Try to “deflate” situation Ask informal questions (how’s Wx at home; how was your flight; how many kids do you have) Make it clear that you are not anxious Move meeting to your turf, quiet place Offer to get coffee, water or soda 90 Aviation Technology Solutions
  • 90. Encounter with FAA Person  Who Continued 1st meeting Understand his/her authority and interest Inquire why the visit If enforcement, remember all of “rules” that you learned during class If not, listen carefully to what FAA person is trying to accomplish and LEARN Take good notes At end of meeting, get concurrence Action items and IOUs Set response dates  Meet or exceed them 91 Aviation Technology Solutions
  • 91. More Who Items  HARD HEADED  Document it, but do it  Assign right people  Keep detailed log  Make considered decision when to go for the “coup de grace”  My Boss made me do it  May not just be excuse  Create legitimate reasons to meet with boss  Meet boss’ agenda  Work to reduce friction Aviation Technology Solutions 92
  • 92. Encounter with FAA Person  Who – had previous meeting  Review previous notes  Touch on any personal relationships established Kids, sports, interests, work experience  Be CERTAIN to reintroduce whatever agenda (office or personal) that you identified before Mention any actions that you have taken or have initiated along that agenda  Follow all ROE mentioned in first encounter Aviation Technology Solutions 93
  • 93. Encounter with FAA Person  Where from  If you do not know where from, ask  Remember organizational chart lessons: If from DC (AVS, AFS,AIR, etc.)  Person has specific job scope (ask)  Inquiry is VERY likely to be on policy If from your region or another region  Ask about job scope/focus  May be special inquiry/investigation  If it is, should have called for appointment – mention/ask  If from your CMO/FSDO  Could be routine  Ask!!! Aviation Technology Solutions 94
  • 94. Why Here/What is Agenda?  IMMEDIATELY assess agenda  Is there enforcement investigation open?  If answer is YES, then Questions you should ask yourself… BE CAREFUL WHAT YOU SAY Take comprehensive notes  If answer is NO, Opportunity to refine/improve relationship Know their agenda and specific hot buttons Aviation Technology Solutions 95
  • 95. What can I do to help  Positive, responsive attitude buys GOODWILL  It helps to have “salesperson’s” skill set  Seemingly stupid questions do not necessarily mean FAA bad attitude, may just reflect lack of knowledge about real world of operators  Take initiative; suggest solutions that BOTH  Make good operational sense  Meets FAA, office and person’s agenda  YOU ARE INFINITELY MORE LIKELY TO DISCERN SUCH OPTIONS Aviation Technology Solutions 96
  • 96. What Can I Do To Help  If FAA person makes 1st suggestion, you will have to “argue” away from that point  Set deadlines, at least meet them; hopefully exceed them  Try to say “NO” in positive response such as, I’d like to get you those documents, but let’s consider two options  Someone from my shop will make copies and have them ready by 3pm in two work days  I can have books available for you to copy by 4pm today? Aviation Technology Solutions 96
  • 97. What Can I Learn From Encounter?  One approach does not fit all  Document, Document, Document  Sloppy, inaccurate records = blood in water for investigators  Maintained, well organized records lead to inspector boredom and case closure  The ultimate in FAA “administrative ease”  Make their job easy and... Aviation Technology Solutions 98
  • 98. What Can I Learn From This Encounter?  Specific Reactions May be headache to adjust Need to do calculus– short term pain v. long term peace Do NOT compromise PRINCIPLES Aviation Technology Solutions 99
  • 99. What Can I Learn From This Encounter?  Review/ Revise Regulatory Action Plan based on each encounter  Soon after encounter  Write report about substance and person(s) involved  Soon afterwards is important Subtle messages/signs will be FRESH and mean more  Facial expression may hint whether request is demand or nice- to-have  Place specific request in context of entire conversation  Brief your management  Send actions/IOUs and report to FAA for confirmation Aviation Technology Solutions 100
  • 100. What Can I Learn From This Encounter? FOLLOW UP; convey that FAA agenda is matter of importance to company Aviation Technology Solutions 101
  • 101. Positive Regulatory Relations  Set own FAA agenda – proactive not reactive Improve records/systems Incorporate specific hot buttons Tell PMI or POI about scheduled company enhancements of non-regulatory systems Share with FAA future commercial developments Create reasons to bolster relations with FSDO, region, HQ leaders Aviation Technology Solutions 102
  • 102. Positive Regulatory Relations, p.2  Conduct regular Meetings with FAA Meet with FSDO or CMO manager monthly Exchange info– LISTEN and LEARN  Follow what’s going on in their world and be sensitive FAA budget likely to be cut Fed pay likely to be frozen Congressional hearings Aviation Technology Solutions 103
  • 103. Positive Regulatory Relations, p3  Get intelligence on FAA trends/issues from your Washington Office, Trade Association or legal counsel  Interpret what appointments mean  Use as reasons to keep in contact with FAA senior leadership  Create “safety net” for when bad things happen  Too late to create positive relationship when major problem is announced  Every bit as importantas preventative maintenance  Use valid reason as predicates for meetings  Ask your Washington office/trade group to include you in meetings with Hill staff (members only if your staff says it is a great idea) Aviation Technology Solutions 104
  • 104. Refresh your Regulatory Relations  Not static plan  Periodically review relationships, goals and plans  Do not get overconfident  Equal weight to other operational plans  Choose staff with the right skills  Make position to be predicate to future promotion within organization Aviation Technology Solutions 104
  • 105. Establish Regulatory Affairs Group  Centralize Reg. Affairs activity  Locate office for FAA convenience/access  Put under Safety maybe legal  Head by MD  SOP  Train staff  Processes, procedures, forms  Collect data  Coordinate responses as focal point Aviation Technology Solutions 105
  • 106. Establish Positive Relationship  Make FAA Agenda Your Priorities  Pay attention to FAA local agenda  Don’t compromise if your are rock solid certain  Look for opportunities to involve FAA early  Non-crisis meetings  Have regular meetings or CCs  Know your PI  Learn their Goals and Objectives  Go beyond local FAA but keep local in loop Aviation Technology Solutions 106
  • 107. Improve Your Regulatory Knowledge  Use tools from course  Go Beyond FAR  Preamble, NPRM and FR comments  ACs’, 8900.1, AD’s and associated references  Contact FAA POC/author  Raising the Bar  Keep it generic – no dispute  Keep records of research, calls - details  FAA Buddy System  Control access, have sign in  Escort  Document visit, documents copied, questions  Document visit and actions  SOP with all line stations  Follow up email/call confirming actions/dates Aviation Technology Solutions 107
  • 108. Outcome  Proactive business approach not reactive  Standard approach for FAA interface  Fewer fines and LOIs  Improved FAA relationships  Positive impact on corporate/safety culture  Improved record keeping  Less crisis management  Lower operating costs Aviation Technology Solutions 108
  • 109. After the Course  Questions about Course Material? Contact instructors by email or phone  Need Support with FAA Issue or LOI?  JDA monthly subscription service or on demand/by the drink  Tailored to company size  Former FAA assigned as rep/assist  Lessons learned  Call JDA at 301-941-1460 ext 140 for details or email JDA at info@jdasolutions.aero Aviation Technology Solutions 109
  • 110. Summary and Feedback Aviation Technology Solutions 110
  • 111. Evaluation Forms and Certificates Aviation Technology Solutions 111
  • 112. 4720 Montgomery Lane Suite 950 Bethesda, MD 20814 www.jdasolutions.aero 301-941-1460 Aviation Technology Solutions 112